New normative instruction strengthens legal certainty for companies subject to the GloBE Rules and advances the implementation of OECD international standards.
By Mauricio Nucci
Legale Overseas, no. 987.
In June 2026, the Brazilian Federal Revenue Service issued Normative Instruction RFB No. 2,329, updating the rules governing the Additional Contribution on Net Profits (CSLL) within the framework of the Global Anti-Base Erosion (GloBE) Rules developed by the Organisation for Economic Co-operation and Development (OECD). The measure enhances operational aspects of tax collection and simplifies the application of the transitional regime for multinational groups with a presence in Brazil.
The CSLL Additional Tax was created to implement in Brazil the Qualified Domestic Minimum Top-up Tax (QDMTT), a mechanism designed to ensure that large multinational business groups pay a minimum level of taxation in each jurisdiction where they operate. The initiative is part of a coordinated global effort led by the OECD to combat base erosion and profit shifting practices.
Among the main changes introduced by the new regulation is the possibility for organizations subject to the GloBE Rules to centralize the payment of the CSLL Additional Tax in a single entity, which will act as both taxpayer and responsible party on behalf of the other entities in the group. To facilitate this arrangement, two separate codes will be used in the Federal Revenue Collection Document (Darf): one for entity-specific payments and another dedicated to centralized payments. The corresponding amounts and calculation data must be reported through the Web Declaration of Federal Tax Debts and Credits (DCTFWeb).
The regulation also introduces adjustments to the application of the GloBE Transitional Safe Harbour (GTSH), a mechanism intended to ease compliance during the transition to the new framework. A key aspect of the update concerns situations in which an organization’s fiscal year does not coincide with the fiscal year applicable in Brazil. In such cases, taxpayers may choose to use the Country-by-Country Report (CbCR) whose fiscal year begins or ends within the relevant jurisdictional fiscal year, thereby avoiding the need to combine information from different reporting periods.
These rules directly affect multinational groups with consolidated annual revenue exceeding €750 million — the threshold established under the OECD GloBE Rules — particularly those with complex corporate structures or operations spread across multiple jurisdictions. Such companies should assess the benefits of adopting centralized payment arrangements, review their tax calculation processes, and ensure the proper fulfillment of ancillary obligations, the specific requirements of which will be established in a future normative instruction.
Vaz de Almeida Advogados closely monitors developments in the regulation of the CSLL Additional Tax and the GloBE Rules in Brazil, analyzing the impacts of new regulations and helping companies subject to this regime understand and adapt to the requirements of global minimum taxation.
Translation Disclaimer
This document was originally drafted in Portuguese and subsequently translated into English using artificial intelligence (AI).
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